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. … Where business expenses have been paid by someone other than the taxpayer carrying on the business, the amounts so paid could, depending on the circumstances, be included in the income of the taxpayer's business or give rise to the application of section 80. ...

. … Nevertheless, the Act will apply to avoid double taxation through the foreign tax credit mechanism. ...

A would have disposed of property for consideration equal to the decrease in the FMV of the common shares he held, pursuant to paragraph 69(1)(b),” CCRA further indicated that a price adjustment clause pursuant to the terms of the preferred shares pursuant to which their redemption value would be adjusted upwards pursuant to a board resolution to reflect the higher FMV was “not a type of price adjustment clause contemplated in … IT-169,” so that such clause would not stop such application of s. 69(1)(b). ...

. … In the second situation, the instalments are paid in respect of income taxes generated by the corporation's active business and the payment of the instalments to the various governments is an obligation of the corporation and is required by the Act or by provincial law. ...

. … [T]he coverage of the risk during the period covered by the premium will benefit the employee (or shareholder) if the employee's (or shareholder's) beneficiaries are the beneficiaries of the life insurance policy during that period. ...

. … [T]he coverage of the risk during the period covered by the premium will benefit the employee (or shareholder) if the employee's (or shareholder's) beneficiaries are the beneficiaries of the life insurance policy during that period. ...

For purposes of computing the s. 125.1(1) credit, should "adjusted business income" include such expense reimbursements, and should such reimbursements reduce Canco’s "labour cost" and "cost of manufacturing and processing labour "? ...

CCRA stated: [I]t seems to us that the arrangement between the employer, the trust and the insurer could resemble a health and welfare trust, provided that the conditions of … IT-85R2 are satisfied, including, among other things, that the employer does not have control over the use of trust funds. ...

X would be allocated his share of the capital gain – but that since the ACB of his partnership interest was increased to FMV under former s. 48(3) on his immigration and further increased by his capital contribution and his share of the capital gain, he would realize a capital loss on the partnership winding-up. ...

In those cases, the trust will be able to apply those expenses against its income other than taxable dividends, including against its net taxable capital gains … in order to allow for the maximum possible flow-through of the dividend tax credit to a beneficiary or beneficiaries, provided that this method does not contravene the legislative provisions relating to trusts or the trust agreement. ...